We will only collect personal information when we need this.  The type of information we need from you will vary depending on our relationship with you.  When we ask you for information, we will make it clear why we need it.  We will also make it clear when you do not have to provide us with information and any consequences of not providing this.

Most information we hold will be collected from you but depending on your circumstances and if this is necessary we will also obtain this from third parties such as:

• the local authority,
• previous landlords,
• solicitors or legal representatives,
• financial advisers, mortgage advisers,
• developers or property agents,
• or other relevant community partner.

At times, we will also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.

We collect information from you (as applicable):

• To set you up as a Leaseholder, Tenant, Shared Owner or Service user and to manage your lease / tenancy.
  • we will need your name and up to date contact details (including your telephone and email address and those of anyone you may choose to represent you*) so we can reach you when we need to discuss issues pertaining to your lease, tenancy or service, e.g. income collection, essential servicing, access for maintenance and improvements, to contact you in the event of an emergency, to respond to complaints/property management issues or to enforce the terms of your tenancy/lease.
  • for retirement properties we will need to collect details of your Next of Kin, emergency contact and/or key holder* should we need to facilitate access to the emergency services.
  • we require details of any change in circumstances (e.g. if you wish for someone to act on your behalf, we will ask for this request to be made in writing) or to effect any changes to your customer record (e.g. if you want to change your name on our records we’ll ask you for a copy of your marriage or deed poll certificate).
  • we will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
  • we will keep financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on your method of payment, we may hold your bank account details.
  • we will collect details relating to the repair, maintenance, and servicing requirements of your home (although this information will not necessarily constitute your personal data).* When you provide information about another individual we assume that you do so with their full knowledge and authority. Provision of the information is a ‘Contractual Requirement’.  Without this information, we are unlikely to be able to manage your services. For example, we cannot provide property management services if we do not hold your contact details in order to collect service charges. Please speak to us with any concerns.

• To meet your needs in our service delivery
  • to ensure our services are accessible, that we take account of any support needs in our dealings with you and to improve our communications with you. For example, if you wish for us to liaise with a carer, or other advocate, if there are considerations we need to be aware of when providing services, if you need large print or translated text.
  • when profiling you for services and to target our resources.
    Where processing information about you or your household members, we may have a legal or contractual obligation to process this information for example to provide inclusive services.It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household.

• To prevent fraud and confirm eligibility for services where applicable
  • we will collect enough information to verify your identity and eligibility for any services with eligibility criteria. Processing for the purpose of fraud prevention is required in order to meet our legal obligations.  Therefore if we are unable to verify your identity we may not be able to provide services to you.

• To understand how we’re performing
  • to monitor our performance and to improve our services to our customers,
  • to segment customers to help target our resources and prioritise services,
  • in managing and analysing complaints,
  • to help us improve how we communicate with our customers,
  • to monitor our website usage so we can make our website better,
  • for statistical analysis.
    It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives. In some situations, we are under a legal obligation to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.

• Supporting agencies with prevention and detection of crime, and quality management.

We do this to meet our legal obligations.

• Meeting our legal obligations including the requirements of our funders or regulators.

This is a legal obligation on Grange and Clarion.

Where relevant, we will also process confidential data about you including bank account information and property access codes.

Grange will not ask you for any special category data However, you may choose to disclose this to us if you feel it is relevant to part of your service.  For example, telling us that a lift repair is urgent because you are a wheelchair user.

Special categories of personal data are:  racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person’s sex life or sexual orientation. Criminal offence data is information that relates to criminal convictions or offences including cautions.

Where Grange processes this type of data about you, it will do so:

• With your consent
• Where we need to protect the vital interests (i.e. the health and safety) of you or another person
• Where you have already made your personal information public
• Where we or another person needs to bring or defend legal claims and/or
• Substantial public interest grounds.

To process personal data about criminal convictions or offences, we must have both a lawful basis for the processing and either legal authority or official authority for the processing.

We use any special category data provided to us to ensure services are delivered appropriately and in the case of certain health information, this will be used for health and safety purposes and / or social protection.

We will apply additional security and confidentiality measures when processing your special category data.

Where you provide consent for us to process special category information, you have the right to withdraw this consent at any time.

There will be times where we will not need your consent to process (including sharing) this type of data.  This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law.

We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

When we need to share personal data with our contractors, third party suppliers and business partners, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.

To help us ensure confidentiality of your personal information we may ask you (and any of your representatives) security questions to confirm your identity when you call us and as necessary when we call you. Apart from where the law permits or requires us to do so, we will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so, there is a court appointed deputyship or Power of Attorney or where we have received a clear verbal instruction from you (as a one-off circumstance).

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.  When sharing information we will comply with all aspects of data protection law.

Where ‘sharing’ is in our legitimate interests, we will share your information with:

• Maintenance contractors and companies providing professional services such as surveyors and consultants to facilitate repairs, maintenance or improvement works, and to enable them to investigate and respond to queries or complaints relating to works to your property, estate and communal areas.
• Other organisations in the Clarion Housing Group.
• Local authority teams such as social services and environmental health.
• Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
• Solicitors.
• Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.

We are also legally permitted to share your information with organisations such as:

• Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
• Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
• Other statutory organisations e.g. social services and health authorities Homes England, the Greater London Authority (GLA), the National Housing Federation, as necessary for exercising statutory functions.
• Council Tax Departments to ensure billing details are correct.

We will also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.

There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA.  Where we do this we will take all necessary steps to ensure that your information remains secure.  You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.

We will routinely use your contact details to send you information and communicate with you about your lease / tenancy / service.  As a customer, we will also tell you about important Grange and Clarion news and events in your area.  If you have a preferred method of contact, you can make this known to us, but we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of your lease / tenancy / contract.

We will never sell your personal data to 3^rd party organisations for marketing purposes.

Grange only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.

We have a document retention schedule which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.

Grange is committed to upholding your rights in respect of your personal data.

The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.

The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).

The best way to do this is to put your request in writing or ask us for a copy of our template form.  When a Subject Access request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.

If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your request. Very broad requests are likely to require clarification so we can make sure we know what information you require.

If someone is requesting information on your behalf they will need written confirmation from you to evidence your authority for us to release this and proof of ID (both yours and theirs).

Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf.

If you choose to make a verbal SAR request, please contact the Contact Centre and request a call back from the Data Protection Team.  We aim to contact you within 2 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.

We have 1 calendar month to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible).  In response to SARs, we will provide you with a copy of the information we hold that relates to you.

Property information such as details of contractor visits, surveys or general property maintenance information is unlikely to constitute your ‘personal information’.  If you ONLY require property related information, you do not need to submit a SAR – you can just contact our Contact Centre.

The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete.  Please help us to keep our records accurate by keeping us informed if your details change.

The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing.  This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data.  Our response will also be guided by the provisions of our retention schedule.

The right to restrict processing
In some circumstances you can ask us to restrict processing, for example

• if you disagree with the accuracy of personal data
• if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate interests override those of yours.

The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this.  Please contact us to discuss.

The right to object
You can tell us if you object to our processing of your personal data:

• based on legitimate interests (including profiling) or for the purpose of historical research purposes. This is not an absolute right and we will need to consider your objection,
• for the purpose of direct marketing (including profiling).

Rights in relation to automated decision making and profiling.
Grange do not undertake any automated decision making or profiling which has a legal or significant effect on you and therefore this right is not relevant.  We will tell you if this position changes.

If you’d like to talk to us about your rights, or report a concern about our processing of your data, you can contact us. Alternatively, if you want to seek an independent view, or report a complaint once we have had the opportunity to respond to you, you can contact the Information Commissioner using the contact details provided at the start of this notice.

As a website user, we will collect:

• Information about your computer and about your visits to and use of this website (including your IP address, your cookie preferences, geographical location, browser type, referral source, length of visit and number of page views);
• Information that you provide to us for the purpose of submitting an enquiry or request including name, email, telephone number and, where relevant, the type of service you are interested in;
• Any other information that you choose to send to us.

We will use this to:

• provide relevant website services, for example, submitting an enquiry on our website;
• monitor the usage of website to help us improve our services;
• produce anonymous statistical information about our website users to help us develop our website and services.

If at any time you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you grant to us.

We also use third party cookies and where necessary will share information about your use of our site with our trusted advertising, analytics and social media partners.

Clarion is not responsible for the privacy policies or practices of third party websites accessed through links on our site.

Cookies are small text files that are sent by websites that you visit for a number of purposes, including to make those websites work, or work more efficiently, and to recognise who you are when you return there. The files are stored on your computer’s hard drive, and are read by your web browser.  For more specific information on the cookies used on our website and the easiest way to manage these, please click on ‘Cookies’ in the footer of our website or please click here.

Alternatively, you can set your browser so that it will not accept and store any cookie, or if you have a little more time and knowledge you are able to allow only certain ‘trusted’ sites to store cookies on your computer.

For further general information visit: www.allaboutcookies.org or www.aboutcookies.org.

See our website for more information on the cookies used.